Nation of Sale: what packaging producers need to know

Introduction

Nation of sale: For UK packaging producers, there's an upcoming, compliance requirement demanding your attention: Nation of Sale data collection. It represents a significant addition to your Extended Producer Responsibility (pEPR) obligations for packaging.

What is Nation of Sale data?

Nation of Sale data confirms where in the UK your packaging ends up - England, Scotland, Wales or Northern Ireland.

Why does this matter?

Each UK nation sets its own waste management and recycling objectives and needs accurate data to track progress. If there is no data on the amount of packaging which ended up in households in, for example, Scotland, then it is not possible to assess what the recycling rate for the nation actually is. When you sell, hire, loan or even gift packaging, you're creating a data point that feeds into these national figures. For imported packaging, the same rules apply and you need to know which nation it's being supplied in.

This requirement applies to a broad range of businesses. If you're a seller, distributor, service provider, online marketplace or importer handling packaging, you're likely caught by these rules. The scope is deliberately wide because regulators need comprehensive data to make the system work.

The legal timeline: what's changed and what hasn't

Here's where things get interesting, and potentially confusing. The legal requirement to collect Nation of Sale data actually began on 1 January 2024. However, a Regulatory Position Statement (RPS) created a grace period delaying the enforcement of Nation of Sale reporting until the end of 2026.

Government has confirmed that the requirement is not being removed from the Regulations and that the RPS is not being extended – so from 1 January 2026, the landscape shifts significantly. This is when mandatory data collection begins in earnest, with enforcement of the requirement expected. Your first official report covering this period is due by 1 April 2027.

Who needs to repo rt Nation of Sale data?

Businesses with an annual turnover over £1 million AND who supply or import more than 25 tonnes of packaging in the UK need to report this data.

This includes both Small Producers and Large Producer – as a reminder these are defined as follows:

Small producers are organisations with either:

• Annual turnover between £1 million and £2 million AND supply or import more than 25 tonnes of packaging in the UK; or
• Annual turnover over £1 million AND supply or import between 25 and 50 tonnes of packaging in the UK

Large producers are organisations with:

• Annual turnover of £2 million or more AND supply or import more than 50 tonnes of packaging in the UK

Both categories must collect and report Nation of Sale data from 1 January 2026, with the first report due by 1 April 2027, after which, reporting will be an ongoing annual requirement.

If you're working with a compliance scheme like ERP UK, you may submit your Nation of Sale data alongside your H2 2026 data, providing some flexibility in your reporting workflow.

The practical challenge: data collection

The theory sounds straightforward, but the practical reality of collecting Nation of Sale data can be complex. Consider these scenarios:

A packaging distributor supplying retailers across the UK needs to track which nation each shipment reaches. An online marketplace must determine where customers receiving packaged goods are located. An importer bringing packaging into the UK must identify the nation which is the final destination for each batch.

For businesses with sophisticated logistics IT systems, this might be manageable. For others, particularly those with complex supply chains or multiple sales channels, it represents a significant operational challenge.

The data needs to be accurate and auditable. You can't simply estimate or use broad assumptions. Regulators expect you to demonstrate how you've determined which nation your packaging was supplied in, and your methodology needs to withstand scrutiny.

Why this matters beyond pEPR compliance

Nation of Sale data serves a genuine environmental purpose that affects how the UK tackles packaging waste.

Each UK nation has devolved responsibility for waste management and sets its own recycling targets. Without accurate data on where packaging is actually supplied, these nations can't properly plan infrastructure, set realistic targets or measure progress. Your data helps determine where recycling facilities are needed, influences policy decisions and shapes the future of the circular economy across the UK.

Getting this right positions your business advantageously. As regulations evolve and enforcement intensifies, businesses with robust data collection systems will adapt more easily than those scrambling to implement systems retrospectively.

Common pitfalls to avoid

Based on early experiences with pEPR compliance, several common mistakes are already emerging. These include:

1. Assuming the RPS means you can ignore 2024 and 2025 data. The enforcement delay doesn't remove the legal obligation.
2. Underestimating data collection complexity. Many businesses assume their existing systems capture the necessary information. Often, they don't. Sales data might show customer locations, but not where packaging is actually supplied to end-users.
3. Waiting until the end of the year to start planning. System changes, staff training and process development all take time.
4. Treating this as a one-off exercise. Nation of Sale reporting will be an ongoing annual requirement. Your data collection processes need to be sustainable, not heroic one-time efforts.

How ERP UK simplifies Nation of Sale compliance

ERP UK has been helping businesses navigate environmental compliance[2] for years, and Nation of Sale data is no exception.

1. Our dedicated account management means you have a knowledgeable contact who understands your specific business model and can provide tailored guidance on data collection approaches.
2. Regulatory expertise keeps you informed as requirements evolve. Having experts monitoring changes means you're never caught off guard.
3. Data reporting support takes the complexity out of submission. Rather than wrestling with Environment Agency portals and reporting formats, you work with systems designed for clarity and efficiency.
4. Compliance scheme membership provides the infrastructure you need without building everything from scratch. ERP UK handles the regulatory interface, allowing you to focus on your core business while meeting your obligations.

ERP UK delivers compliance made simple through expertise you can trust. We serve over 700 businesses of various sizes, from small producers to large organisations with complex packaging portfolios.

Preparing for 2026: Nation of Sale your action plan

With mandatory data collection beginning 1 January 2026, now is the time to prepare:

• Audit your current systems. Can you currently identify which UK nation or nations your packaging is supplied in? If not, what changes are needed?
• Map your supply chain. Understand all the points where packaging moves through your business and where data capture needs to happen.
• Engage with your compliance scheme. If you're already working with ERP UK, discuss your Nation of Sale data strategy. If you're not yet a member, explore how membership could simplify your compliance journey.
• Train your team. The people handling sales, distribution and logistics need to understand why this data matters and how to capture it accurately.
• Test your processes. Don't wait until 2027 to discover your data collection approach doesn't work.

Take action today

Nation of Sale requirements represent a significant compliance challenge, but you don't have to face it alone. Whether you're a small producer, or a large organisation with complex packaging flows, ERP UK provides the partnership you need to navigate Nation of Sale requirements confidently.

Ready to simplify your pEPR compliance?

Contact ERP UK today to discuss how our compliance scheme membership can support your Nation of Sale data collection and reporting. With dedicated account management, regulatory expertise and proven systems, we'll help you meet your obligations while focusing on what you do best - running your business.

Related services

Extended Producer Responsibility - visit the webpage here

About ERP UK

To learn more about ERP UK and our services please visit our About page

Contact us today:

Telephone: +44 (0)20 3142 6452

E-mail: uk@erp-recycling.org

Follow ERP UK on LinkedIn here: